RESUBMISSION OF PUBLIC INFORMATION REQUEST AND FORMAL COMPLAINT — WILLIAMSON COUNTY JAIL
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Fri 10/24/2025 4:20 PM
=========================================== RESUBMISSION OF PUBLIC INFORMATION REQUEST AND FORMAL COMPLAINT — WILLIAMSON COUNTY JAIL =========================================== Date: October 14, 2025 To: Texas Commission on Jail Standards (TCJS)
Ricky Armstrong<ricky.armstrong@tcjs.state.tx.us>
You;info
A comprehensive inspection of the Williamson County Jail was conducted on September 3rd and 4th, 2025. During the inspection, Inspector Garrett reviewed all applicable Minimum Jail Standards.
No deficiencies were noted.
Specifically, noted in your complaint was
– **§§273.1–273.5** – Health Services, Emergency Procedures, and Medical Instructions
– **§283.3** – Use of Restraints
– **§275.1** – Complaint Review and Inmate Grievance Process
The following standards under the Texas Administrative Code, Title 37, Part 9 were reviewed during the September inspection, and no violations were found:
- §273 Health Services
- §273.6 Use of Restraints
- §283 Discipline and Grievances
Ricky Armstrong
Assistant Director
Texas Commission on Jail Standards
512-653-4346 Phone
512-463-3185 Fax
Ricky.armstrong@tcjs.state.tx.us
[Draft]
LeRoy Nellis
4845 Twin Valley Drive
Austin, Texas 78731
Phone: 512-450-1533
Email: LeRoyNellis2@gmail.com
October 27, 2025
To:
Mr. Ricky Armstrong
Assistant Director
Texas Commission on Jail Standards (TCJS)
P.O. Box 12985
Austin, Texas 78711-2985
Email: ricky.armstrong@tcjs.state.tx.us
and
U.S. Department of Justice
Civil Rights Division – Special Litigation Section (CRIPA)
950 Pennsylvania Avenue N.W.
Washington, D.C. 20530
Email: special.litigation@usdoj.gov
Subject: FORMAL REBUTTAL AND REQUEST FOR JOINT INVESTIGATION
— WILLIAMSON COUNTY JAIL, GEORGETOWN, TEXAS
Dear Mr. Armstrong and Civil Rights Division Officials:
This correspondence serves as both a formal rebuttal to the Texas Commission on Jail Standards’ (TCJS) October 24, 2025 finding of “no deficiencies,” and a formal complaint and request for federal investigation under the Civil Rights of Institutionalized Persons Act (CRIPA), 34 U.S.C. §12601.
I. First-Hand Experience and Physical Harm
From January 3, 2024 through July 11, 2025, I endured sustained medical neglect, retaliatory confinement, and unlawful restraint inside the Williamson County Jail.
During that period I:
* Spent 326 days in solitary confinement under constant fluorescent lighting, sleep deprivation, and vibration.
* Was denied diabetic medication and glucose monitoring for 126 days, despite a known Type-2 diabetes diagnosis.
* Suffered permanent vision loss and neuropathic nerve damage caused by forced insulin injections and untreated infections.
* Experienced severe kidney pain and urinated blood for several days without medical transport or diagnostic care.
* Was restrained in a restraint chair solely because I refused to surrender my Bible, constituting both religious retaliation and medical abuse.
* Was placed in a SMOK (suicide-monitoring observation cell) and held under suicide watch immediately after passing an independent psychiatric evaluation, on the false recommendation of unlicensed Dr. Ghulam M. Kahn (Kahn).
* Received medication and injections from jail staff and EMTs wearing “EMT” patches, none of whom held valid prescriptive authority.
* Was treated by “Dr.” Alan Brooks and “Dr.” Ghulam M. Kahn—neither of whom maintain active Texas medical licenses.
* Later confirmed that all prescriptions were being authorized by a Houston-based physician who never examined or communicated with any inmate, functioning only as a remote signatory.
These combined actions inflicted permanent disability and psychological trauma and constitute deliberate indifference and cruel and unusual punishment.
II. Basis for Rebuttal and Federal Referral
1. Contradictory Findings
TCJS’s “no deficiencies” finding conflicts with the record of part-time psychiatric coverage, unlicensed medical practice, and corroborated injury.
2. Part-Time and Unlicensed Medical Coverage
Every physician listed between 2018–2025 was contracted for 8–20 hours weekly; unlicensed EMTs performed the majority of care.
3. Restraint, Isolation, and Suicide-Watch Abuse
* In addition to the documented Tijerina v. Williamson County settlement (Oct 14 2025; $1.15 million) for restraint-chair injuries, I was personally strapped into a restraint chair after declining to surrender my Bible—an act of protected religious expression.
* After passing an independent psychiatric evaluation showing no suicidal risk, I was nonetheless placed in a SMOK cell and kept under suicide watch on the false recommendation of unlicensed Dr. Kahn.
These actions violate Tex. Admin. Code § 273.6(c) (restraint use), § 273.5(a) (mental-health procedures), and the First and Fourteenth Amendments.
4. Conflict of Interest
Chief Kathleen A. Pokluda’s dual roles as former TCJS employee and current Williamson County medical administrator render the 2025 inspection unreliable and compromised.
III. Legal Framework
State Law:
Tex. Admin. Code Title 37 Part 9 §§ 273.1–273.6; Tex. Occ. Code § 157; Tex. Health & Safety Code Chs. 571–578.
Federal Law:
Estelle v. Gamble, 429 U.S. 97 (1976); Kingsley v. Hendrickson, 576 U.S. 389 (2015); Turner v. Safley, 482 U.S. 78 (1987); and CRIPA (34 U.S.C. § 12601).
IV. Requested Actions
1. Joint Re-Inspection and Forensic Review
A coordinated TCJS + DOJ inquiry should:
• Verify licensing of all medical and psychiatric personnel;
• Audit all medication, restraint, and suicide-watch records (Jan 2024–Jul 2025);
• Review grievance responses and disciplinary files;
• Inspect and document the vibration or “shaking” devices located in cells B5-L6, B7-R6, B9-R1, C14-R8, and within the dayrooms of B9 and C14, collecting frequency and seismic data and associated maintenance or engineering records.
2. Independent Oversight
Assign inspectors and medical experts with no prior affiliation to Williamson County or TCJS.
3. Federal Pattern-or-Practice Investigation
Initiate a CRIPA action addressing systemic medical neglect, unauthorized practice of medicine, retaliation, and religious discrimination.
4. Transparency and Disclosure
Release the full September 2025 TCJS inspection report—including staff rosters, notes, and correspondence—to this complainant and the public.
5. Acknowledgment and Case Number
Provide written acknowledgment, issue a joint DOJ/TCJS case number, and specify a response timeline.
V. Attached Exhibits
| Exhibit | Title | Description |
|———-|——–|————-|
| A | Texas Jail & Pre-Trial Detention Summary (2024–2025) | Statewide evidence of medical neglect |
| B | Williamson County Medical Research Summary | Contract and inspection analysis |
| C | Williamson County Jail Medical & Psychiatric Hiring Record (2018–2025) | Documentation of part-time staffing |
| D | Systemic Medical Abuse in Williamson County Jail | First-hand narrative of unlicensed practice and resulting injuries |
VI. Certification
I certify under penalty of perjury that the information provided herein and in the attached exhibits is true and correct to the best of my knowledge, and that this complaint is submitted in good faith for lawful oversight and enforcement.
Respectfully,
___________________________
LeRoy Nellis II
4845 Twin Valley Drive
Austin, Texas 78731
Phone 512-450-1533 Email LeRoyNellis2@gmail.com
Date: October 27, 2025
¹ Note: The “shaking” or vibration-emitting devices were active in cells B5-L6, B7-R6, B9-R1, C14-R8, and in the dayrooms of B9 and C14 during my confinement. They produced persistent low-frequency tremors that disrupted sleep and caused physical distress; forensic inspection is required to determine their source and authorization.
===========================================================
EXHIBIT A
TEXAS JAIL & PRETRIAL DETENTION CASE SUMMARY (2024–2025)
Compiled for Investigative / Legal Use — © LeRoy Nellis
===========================================================
COUNTY: WILLIAMSON (Georgetown)
———————————————————–
2024–2025 CASES:
• Acosta v. Williamson County (5th Cir. 2024)
– Facts: Pretrial detainee denied diabetic treatment; near-fatal complication.
– Holding: 5th Circuit recognized viable medical-care claim.
• Holman v. Williamson County (2025)
– Facts: Wrong medication; stroke-like symptoms; delayed release.
• TCJS 2025 log lists open death-in-custody investigation for Williamson Jail.
RELEVANCE:
– Demonstrates pattern of medical-care negligence.
– Supports systemic-failure argument under Fourteenth Amendment.
———————————————————–
STATEWIDE CONTEXT (2024–2025)
———————————————————–
• 30+ Texas counties cited for health-service noncompliance (TCJS Annual Report 2024).
• State Auditor Report (2025): “Oversight Gaps in Jail Safety and Complaint Resolution.”
• DOJ / Civil Rights Division: Active pattern-or-practice probes in Harris, Bexar, Dallas, Williamson, El Paso.
• Texas Rangers: Investigating 2025 deaths in Harris, Hidalgo, and Williamson Counties.
• Wellpath Bankruptcy (2024–25): Hundreds of nationwide jail-medical negligence suits.
RELEVANCE:
– Confirms uniform statewide pattern of deliberate indifference.
– Establishes foreseeability and failure to correct known violations.
– Strengthens argument for injunctive relief and federal oversight.
===========================================================
END OF EXHIBIT A
===========================================================
===========================================================
EXHIBIT B
WILLIAMSON COUNTY MEDICAL RESEARCH SUMMARY
===========================================================
Overview:
Williamson County Jail’s healthcare program operates primarily on part-time psychiatric contracts and mid-level providers (EMTs, NPs), without full-time licensed physician oversight.
Key Findings:
• Psychiatric Services Contract (2008) — Dr. Michael Musgrove: up to 20 hrs/week “as needed.”
• Psychiatric Medical Services (FY22–25) — Dr. Ghulam M. Khan: similar 16–20 hrs/week model.
• 2025 job listing (Adelphi Medical Staffing): 16 hrs/week psychiatrist, $250–$285/hr.
• Nurse Practitioner added 2022 under ARPA funds — responsible for 550–600 inmates.
Inspection History:
• TCJS 2019 inspection: two inmates never received physician-ordered specialist appointments.
• Williamson County listed as “Special Inspection / Non-Compliant Jail.”
• No later report confirming 24/7 licensed coverage or corrected deficiencies.
Concerns:
• Heavy reliance on mid-level practitioners without direct MD supervision.
• Psychotropic medications prescribed with intermittent physician oversight.
• Evidence of “Orders to Administer Psychoactive Medications” suggesting involuntary treatment.
• No transparent data on license verification or prescribing logs.
Implications:
• Potential violation of Tex. Admin. Code §273.2 & §273.5 (24-hr health services and supervision).
• Possible breaches of Tex. Occ. Code §157 (prescriptive delegation) and Fourteenth Amendment rights.
Conclusion:
The jail’s “as-needed” contracting model fails to ensure continuous licensed medical care, creating foreseeable risk of harm and statutory noncompliance.
===========================================================
END OF EXHIBIT B
===========================================================
===========================================================
EXHIBIT C
WILLIAMSON COUNTY JAIL MEDICAL & PSYCHIATRIC HIRING RECORD
(2018 – 2025)
===========================================================
Year Position Title Type & Hours Prescribing Authority Notes / Source
——————————————————————————————————–
2025 Psychiatrist Physician (Adelphi LLC) Contract 16 hrs/wk ✅ Psychotropic meds per Sheriff’s formulary
2025 Part-Time Psychiatrist (GreenLife) As-needed ✅ General medication management
2024 Dr. Ghulam M. Khan (FY22–25 Contract) Renewal Contract ✅ Professional Services Agreement
2022 Nurse Practitioner – Jail Full-time 7-day ⚠️ Mid-level prescriber (supervised by MD)
2019 Corrections Medical Officer Full-time ❌ Dispenses meds only as ordered
2018 Medic – Jail Full-time ❌ Assists MD/psychiatrist, schedules appts
2008 Dr. Michael Musgrove (Psychiatrist) 20 hrs/wk “as needed” ✅ Licensed psychiatrist per contract
Patterns:
• Continuous use of short-hour, part-time psychiatrist contracts (8–20 hrs/wk).
• Mid-level or unlicensed personnel handle most daily care.
• No evidence of 24/7 on-site licensed medical coverage.
Conclusion:
Part-time psychiatry and intermittent MD oversight produce structural gaps incompatible with TAC §273’s 24-hour coverage requirement.
===========================================================
END OF EXHIBIT C
===========================================================
===========================================================
EXHIBIT D
SYSTEMIC MEDICAL ABUSE IN WILLIAMSON COUNTY JAIL:
How Part-Time Medicine and Unlicensed Practice Destroyed My Health
By LeRoy Nellis
===========================================================
Summary:
First-hand, documented account of deliberate medical neglect, unlicensed practice, and part-time physician coverage within Williamson County Jail, resulting in permanent disability.
Key Facts:
• Pre-trial detainee denied diabetic treatment from May 25–July 11, 2025 (108 days).
• Injections administered by EMT Larry R. Davis and others lacking verified medical licenses.
• “Dr.” Alan Brooks practiced without Texas medical license; “Dr.” Ghulam M. Khan and remote Houston doctor approved prescriptions without evaluation.
• 326 days in solitary confinement under continuous light exposure and medical deprivation.
• Result: Nerve damage, vision loss, chronic pain, and disability.
Supporting Evidence:
• County contracts show psychiatrists limited to 16–20 hrs/week for 550–600 inmates.
• 2019 TCJS inspection cited failure to follow physician orders.
• 2025 settlement (*Tijerina v. Williamson County*) proves restraint-chair abuse and denial of care.
• Chief Kathleen A. Pokluda — dual role as TCJS alumna and jail medical chief — potential oversight conflict.
Legal Basis:
• Violations of Eighth and Fourteenth Amendments (Estelle v. Gamble, Kingsley v. Hendrickson).
• Breach of Tex. Admin. Code §§273.1–273.6 (medical coverage and restraint standards).
• Breach of Tex. Occ. Code §157 (prescriptive authority).
• Constitutes “deliberate indifference” and administrative torture under CRIPA (34 U.S.C. §12601).
Conclusion:
Williamson County Jail’s medical program operates as a cost-saving regime of part-time medicine, unlicensed authority, and retaliatory neglect—amounting to systemic, state-sanctioned abuse.
Re-inspection and federal intervention are warranted immediately.
===========================================================
END OF EXHIBIT D
===========================================================
===========================================================
EXHIBIT A
TEXAS JAIL & PRETRIAL DETENTION CASE SUMMARY (2024–2025)
Compiled for Investigative / Legal Use — © LeRoy Nellis
===========================================================
COUNTY: WILLIAMSON (Georgetown)
———————————————————–
2024–2025 CASES:
• Acosta v. Williamson County (5th Cir. 2024)
– Facts: Pretrial detainee denied diabetic treatment; near-fatal complication.
– Holding: 5th Circuit recognized viable medical-care claim.
• Holman v. Williamson County (2025)
– Facts: Wrong medication; stroke-like symptoms; delayed release.
• TCJS 2025 log lists open death-in-custody investigation for Williamson Jail.
RELEVANCE:
– Demonstrates pattern of medical-care negligence.
– Supports systemic-failure argument under Fourteenth Amendment.
———————————————————–
STATEWIDE CONTEXT (2024–2025)
———————————————————–
• 30+ Texas counties cited for health-service noncompliance (TCJS Annual Report 2024).
• State Auditor Report (2025): “Oversight Gaps in Jail Safety and Complaint Resolution.”
• DOJ / Civil Rights Division: Active pattern-or-practice probes in Harris, Bexar, Dallas, Williamson, El Paso.
• Texas Rangers: Investigating 2025 deaths in Harris, Hidalgo, and Williamson Counties.
• Wellpath Bankruptcy (2024–25): Hundreds of nationwide jail-medical negligence suits.
RELEVANCE:
– Confirms uniform statewide pattern of deliberate indifference.
– Establishes foreseeability and failure to correct known violations.
– Strengthens argument for injunctive relief and federal oversight.
===========================================================
END OF EXHIBIT A
===========================================================
===========================================================
EXHIBIT B
WILLIAMSON COUNTY MEDICAL RESEARCH SUMMARY
===========================================================
Overview:
Williamson County Jail’s healthcare program operates primarily on part-time psychiatric contracts and mid-level providers (EMTs, NPs), without full-time licensed physician oversight.
Key Findings:
• Psychiatric Services Contract (2008) — Dr. Michael Musgrove: up to 20 hrs/week “as needed.”
• Psychiatric Medical Services (FY22–25) — Dr. Ghulam M. Khan: similar 16–20 hrs/week model.
• 2025 job listing (Adelphi Medical Staffing): 16 hrs/week psychiatrist, $250–$285/hr.
• Nurse Practitioner added 2022 under ARPA funds — responsible for 550–600 inmates.
Inspection History:
• TCJS 2019 inspection: two inmates never received physician-ordered specialist appointments.
• Williamson County listed as “Special Inspection / Non-Compliant Jail.”
• No later report confirming 24/7 licensed coverage or corrected deficiencies.
Concerns:
• Heavy reliance on mid-level practitioners without direct MD supervision.
• Psychotropic medications prescribed with intermittent physician oversight.
• Evidence of “Orders to Administer Psychoactive Medications” suggesting involuntary treatment.
• No transparent data on license verification or prescribing logs.
Implications:
• Potential violation of Tex. Admin. Code §273.2 & §273.5 (24-hr health services and supervision).
• Possible breaches of Tex. Occ. Code §157 (prescriptive delegation) and Fourteenth Amendment rights.
Conclusion:
The jail’s “as-needed” contracting model fails to ensure continuous licensed medical care, creating foreseeable risk of harm and statutory noncompliance.
===========================================================
END OF EXHIBIT B
===========================================================
===========================================================
EXHIBIT C
WILLIAMSON COUNTY JAIL MEDICAL & PSYCHIATRIC HIRING RECORD
(2018 – 2025)
===========================================================
Year Position Title Type & Hours Prescribing Authority Notes / Source
——————————————————————————————————–
2025 Psychiatrist Physician (Adelphi LLC) Contract 16 hrs/wk ✅ Psychotropic meds per Sheriff’s formulary
2025 Part-Time Psychiatrist (GreenLife) As-needed ✅ General medication management
2024 Dr. Ghulam M. Khan (FY22–25 Contract) Renewal Contract ✅ Professional Services Agreement
2022 Nurse Practitioner – Jail Full-time 7-day ⚠️ Mid-level prescriber (supervised by MD)
2019 Corrections Medical Officer Full-time ❌ Dispenses meds only as ordered
2018 Medic – Jail Full-time ❌ Assists MD/psychiatrist, schedules appts
2008 Dr. Michael Musgrove (Psychiatrist) 20 hrs/wk “as needed” ✅ Licensed psychiatrist per contract
Patterns:
• Continuous use of short-hour, part-time psychiatrist contracts (8–20 hrs/wk).
• Mid-level or unlicensed personnel handle most daily care.
• No evidence of 24/7 on-site licensed medical coverage.
Conclusion:
Part-time psychiatry and intermittent MD oversight produce structural gaps incompatible with TAC §273’s 24-hour coverage requirement.
===========================================================
END OF EXHIBIT C
===========================================================
===========================================================
EXHIBIT D
SYSTEMIC MEDICAL ABUSE IN WILLIAMSON COUNTY JAIL:
How Part-Time Medicine and Unlicensed Practice Destroyed My Health
By LeRoy Nellis
===========================================================
Summary:
First-hand, documented account of deliberate medical neglect, unlicensed practice, and part-time physician coverage within Williamson County Jail, resulting in permanent disability.
Key Facts:
• Pre-trial detainee denied diabetic treatment from May 25–July 11, 2025 (108 days).
• Injections administered by EMT Larry R. Davis and others lacking verified medical licenses.
• “Dr.” Alan Brooks practiced without Texas medical license; “Dr.” Ghulam M. Khan and remote Houston doctor approved prescriptions without evaluation.
• 326 days in solitary confinement under continuous light exposure and medical deprivation.
• Result: Nerve damage, vision loss, chronic pain, and disability.
Supporting Evidence:
• County contracts show psychiatrists limited to 16–20 hrs/week for 550–600 inmates.
• 2019 TCJS inspection cited failure to follow physician orders.
• 2025 settlement (*Tijerina v. Williamson County*) proves restraint-chair abuse and denial of care.
• Chief Kathleen A. Pokluda — dual role as TCJS alumna and jail medical chief — potential oversight conflict.
Legal Basis:
• Violations of Eighth and Fourteenth Amendments (Estelle v. Gamble, Kingsley v. Hendrickson).
• Breach of Tex. Admin. Code §§273.1–273.6 (medical coverage and restraint standards).
• Breach of Tex. Occ. Code §157 (prescriptive authority).
• Constitutes “deliberate indifference” and administrative torture under CRIPA (34 U.S.C. §12601).
Conclusion:
Williamson County Jail’s medical program operates as a cost-saving regime of part-time medicine, unlicensed authority, and retaliatory neglect—amounting to systemic, state-sanctioned abuse.
Re-inspection and federal intervention are warranted immediately.
===========================================================
END OF EXHIBIT D
===========================================================
LeRoy Nellis 
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